Apple: we have full documentation that we followed every single Irish tax law.
EU: But you still paid too little tax!!! You didn't pay your fair share!!!! Give us the $1 billion
Apple: But you still have not cited the law we broke
EU: Well, one of your Irish corporations paid a 0% rate
Apple: that was part of Irish law in 2007. Any company could have done the same.
EU: But, but, but, but, but............To little taxes! Pay your fair share!
Apple: Again what law did we break and we will pay the tax.
EU: Damn it!!! You broke no law but you broke the spirit of the law!
Keep taking the pills. You have an overactive imagination. I'm sure the ruling will spell out why the EU considers the deal Apple had with Ireland to be against EU rules but you keep on dreaming about nonsensical conversations.
Then tell me what rule Apple broke. Tell me. Don't just say they broke a rule.
Tim Cook specificly said they BROKE NO RULES. Sorry I trust Tim Cook to say the truth than those liars at the EU.
So what specific rule did they break?
Not again!!!!
Apple didn't really break any rule, the Irish government did. This ruling by the EU will be aimed at the Irish government.
The specific rule is that a government is not allowed to give what amounts to state aid to a company preferentially over other companies so as to have the effect of giving that company an advantage other companies couldn't avail of.
In this instance, the state aid was in the form of a a tax break unavailable to other companies. To right the wrong, the Irish government will be told to collect the tax from Apple it should have in the first place to ensure they will have paid the same rate of tax that is levied on other companies.
You are wrong.
Other companies could have used the same 'tax break' as Apple. And many US companies did.
Using a seperate Irish company (the Double Irish) and using transfer pricing would give you a very low tax rate. THIS WAS AVAILABLE TO ALL COMPANIES IN IRELAND. PERIOD. THUS THERE WAS NO STATE AID SINCE IT WAS AVAILABLE TO ALL.
Now again show me what tax law Apple broke.
This has nothing to do with Double Irish. It has to do with SECRET deals of Irish government with some companies
Screw those new jobs that Apple was planning in that country!
Apple should take its business elsewhere, there are plenty of other places to choose!
So where in the EU should they go? They still need an eu Base and would still have to pay the tax.
Good point! I suppose that they do need a EU base.
In that case, Apple should raise the price of all products offered in the EU zone, to compensate for the illegal tax rape and to offset any loss of profits and income, because of the mob shake down.
It is not rape or a shake down - Apple and Ireland have broken a well established and known law. They thought they could get away with it and did not.... Quite frankly I think that the normal 12.5 % corporate tax in Ireland is already low enough - that's what happens when you get greedy. How much would it have been in the US? They already got a great deal...
Tell me the rule Apple broke or STFU.
Just saying that Apple paid less than 12.5% is not breaking a rule. In 2007 any corporation could set up another Irish corporation that would pay 0% tax using transfer pricing (loophole has been closed in 2015). That was not breaking a rule. That is smart tax strategy.
Right, you seem to be missing the point, and you're not alone; seems that the anti-Apple crowd, in their usual gleeful Golem-like hand-rubbing, have missed it too.
This is not just about Apple: Google, Microsoft, Starbucks etc all use the same arrangement. What the EU is saying is that the arrangement itself is illegal, so Ireland will have to claw back the money from these outfits too.
The mistake that these companies made (and Microsoft keeps making) is that when it comes to these cases they can't really win because the EU is both the jury and the judge. Now since Ireland offered this deal to everyone then I'm a little unclear as to why these companies are getting an unfair advantage; it could be that offer wasn't open to everyone. No one seems to have the full details, but it looks like we'll find out tomorrow.
In any case calm down. This is not going to make any difference to Apple's books since the company has already (wisely as it turns out) accounted for the full amount of tax owed.
As for the EU itself; yes, it is coming apart at the seams (the UK stubbornly failed to implode after Brexit, so other countries will want to leave too), but that won't affect this judgement.
Screw those new jobs that Apple was planning in that country!
Apple should take its business elsewhere, there are plenty of other places to choose!
So where in the EU should they go? They still need an eu Base and would still have to pay the tax.
Good point! I suppose that they do need a EU base.
In that case, Apple should raise the price of all products offered in the EU zone, to compensate for the illegal tax rape and to offset any loss of profits and income, because of the mob shake down.
It is not rape or a shake down - Apple and Ireland have broken a well established and known law. They thought they could get away with it and did not.... Quite frankly I think that the normal 12.5 % corporate tax in Ireland is already low enough - that's what happens when you get greedy. How much would it have been in the US? They already got a great deal...
Tell me the rule Apple broke or STFU.
Just saying that Apple paid less than 12.5% is not breaking a rule. In 2007 any corporation could set up another Irish corporation that would pay 0% tax using transfer pricing (loophole has been closed in 2015). That was not breaking a rule. That is smart tax strategy.
Right, you seem to be missing the point, and you're not alone; seems that the anti-Apple crowd, in their usual gleeful Golem-like hand-rubbing, have missed it too.
This is not just about Apple: Google, Microsoft, Starbucks etc all use the same arrangement. What the EU is saying is that the arrangement itself is illegal, so Ireland will have to claw back the money from these outfits too.
The mistake that these companies made (and Microsoft keeps making) is that when it comes to these cases they can't really win because the EU is both the jury and the judge. Now since Ireland offered this deal to everyone then I'm a little unclear as to why these companies are getting an unfair advantage; it could be that offer wasn't open to everyone. No one seems to have the full details, but it looks like we'll find out tomorrow.
In any case calm down. This is not going to make any difference to Apple's books since the company has already (wisely as it turns out) accounted for the full amount of tax owed.
As for the EU itself; yes, it is coming apart at the seams (the UK stubbornly failed to implode after Brexit, so other countries will want to leave too), but that won't affect this judgement.
No, the deal was not offered to anyone, that is the case about.
And what Brexit? I didn't knew that UK had already triggered the Article 50 of the Lisbon Treaty and had leaved the EU
This will go to appeal and be stuck for at least 3 years. Then the US government will pass a law to bring back the cash to the USA. There will be no cash in the EU for them to collect.
Eventually they will settle for about $200 million.
Or nothing at all. The US government is taking this issue seriously with the EU, and this could end up becoming a major Trans-Atlantic spat. Lots of US companies are involved, not just Apple. This is far, far bigger than just one company.
Correct. This is more like sour grapes between the EU and Ireland because Ireland has become an advantageous business nexus for international companies. While Apple is simply the high profile example and may have benefited from some very custom tailored tax laws this still affects thousands of US businesses that use Ireland as their EU headquarters. In the US this is very similar to states that give tax breaks and other incentives for companies to relocate to their states. Often it is the poorer states that receive the most federal tax subsidies that offer the best breaks. The EU wants to establish a system of fairness among its member nations but I believe this is going too far. The US could very easily decide to renegotiate its tax treaties and penalize the EU for this.
This will go to appeal and be stuck for at least 3 years. Then the US government will pass a law to bring back the cash to the USA. There will be no cash in the EU for them to collect.
Eventually they will settle for about $200 million.
Or nothing at all. The US government is taking this issue seriously with the EU, and this could end up becoming a major Trans-Atlantic spat. Lots of US companies are involved, not just Apple. This is far, far bigger than just one company.
Correct. This is more like sour grapes between the EU and Ireland because Ireland has become an advantageous business nexus for international companies.
No sir. Luxembourg and Netherlands already got the same treatment from the EU Commission regarding "special tax arrangements" with big multinationals, tho not nearly as big as Apple. Still to come are investigations involving Estonia and Poland over the same type of "special tax" deals. http://europa.eu/rapid/press-release_IP-15-5140_en.htm
Planning on not doing business in the EU then (a retarted person's retaliation plan)? Then don't!
That is definitely an option that Apple should consider, when it comes to certain troublesome govts around the world, be it China, or the EU or whoever. There should always be a back up plan, and if worst comes to worst, then Apple need not sell in certain countries. Let them do without Apple products. Give them Android, see if I care.
It makes zero difference to me if Apple has 200 Billion in cash or 300 or more. Apple doesn't need to sell to every person on the globe or to every country in the world.
This will go to appeal and be stuck for at least 3 years. Then the US government will pass a law to bring back the cash to the USA. There will be no cash in the EU for them to collect.
Eventually they will settle for about $200 million.
Or nothing at all. The US government is taking this issue seriously with the EU, and this could end up becoming a major Trans-Atlantic spat. Lots of US companies are involved, not just Apple. This is far, far bigger than just one company.
The US government will be risking a trade war if it takes any action/s other than verbal opinions. The TTIP trade deal is dead as they couldn't agree on a single issue out of the 27.
So? You think this is the first time such jawboning has happened? C'mon...
No, I don't think this is the first time. Do you think it's worth a trade war? Although part of me wonders if that might not actually shock the world out of the economic twilight zone it seems currently stuck in.
All trade negotiations risk a trade war. But trade wars rarely happen, so clearly the negotiations must work more (and better) than you think.
In any event, the EU is far from a bastion of free trade for anything outside of intra-EU trade.
All these Americans on this forum thinking, writing, screw EU, screw rules, appeals, just sit it out, the US govt will tackle this, ...
blah.blah.blah
remember the MDD-Boeing merger? Remember how vocal the US were against EU anti-trust scrutiny? Did it help? No!
The US have 0 authority in the EU. Planning on not doing business in the EU then (a retarted person's retaliation plan)? Then don't!
You fail to see the big picture here. The U.S. does have the upper hand. If an unfavorable ruling is handed down. Ireland will be appealing the decision. That could take at least 3 years. In the meantime, if the U.S. passes repatriation tax reform next year, then all of Apple's money will be out of reach of the EU.
Planning on not doing business in the EU then (a retarted person's retaliation plan)? Then don't!
That is definitely an option that Apple should consider, when it comes to certain troublesome govts around the world, be it China, or the EU or whoever. There should always be a back up plan, and if worst comes to worst, then Apple need not sell in certain countries. Let them do without Apple products. Give them Android, see if I care.
It makes zero difference to me if Apple has 200 Billion in cash or 300 or more. Apple doesn't need to sell to every person on the globe or to every country in the world.
So you want Apple to sacrifice ~20% of its profit? If after all the appeals Apple will pay if they have to because they would have to be totally insane to give up the EU as a market.
Apple products are already more costly in the EU than in the US and Apple also has a lucrative shakedown of its own with respect to how they transfer their patents to the Apple Operations International in Ireland. Their various other country headquarters then license the use of these patents at a high fee which is passed on to the consumer thus making the product more expensive for Europe, but all the money stays within Apple Operations International and since it is transferred to the Irish headquarters where the patents are registered they pay minimal taxes on any income derived from those patents.
Other companies could have used the same 'tax break' as Apple. And many US companies did.
Using a seperate Irish company (the Double Irish) and using transfer pricing would give you a very low tax rate. THIS WAS AVAILABLE TO ALL COMPANIES IN IRELAND. PERIOD. THUS THERE WAS NO STATE AID SINCE IT WAS AVAILABLE TO ALL.
Now again show me what tax law Apple broke.
The fact that you still have not got a simple, clear response tells you all you need to know. There are a lot of cheap name-callers among the pro-EU types here (and I've flagged one of them), but not a lot of honest responses to an obvious question.
All these Americans on this forum thinking, writing, screw EU, screw rules, appeals, just sit it out, the US govt will tackle this, ...
blah.blah.blah
remember the MDD-Boeing merger? Remember how vocal the US were against EU anti-trust scrutiny? Did it help? No!
The US have 0 authority in the EU. Planning on not doing business in the EU then (a retarted person's retaliation plan)? Then don't!
You fail to see the big picture here. The U.S. does have the upper hand. If an unfavorable ruling is handed down. Ireland will be appealing the decision. That could take at least 3 years. In the meantime, if the U.S. passes repatriation tax reform next year, then all of Apple's money will be out of reach of the EU.
How's that? You honestly thing Apple is "repatriating" a couple hundred $B to the US even if the corporate rate here was cut in half? Won't happen.
Other companies could have used the same 'tax break' as Apple. And many US companies did.
Using a seperate Irish company (the Double Irish) and using transfer pricing would give you a very low tax rate. THIS WAS AVAILABLE TO ALL COMPANIES IN IRELAND. PERIOD. THUS THERE WAS NO STATE AID SINCE IT WAS AVAILABLE TO ALL.
Now again show me what tax law Apple broke.
The fact that you still have not got a simple, clear response tells you all you need to know. There are a not of cheap name-callers among the pro-EU types here (and I've flagged one of them), but not a lot of honest responses to an obvious question.
The, fact that has been explained a lot of time tells all we need to know., There are a lot of people here that doesn't know anything and doesn't want to know/ Do you know an honest and clear answer?
This will go to appeal and be stuck for at least 3 years. Then the US government will pass a law to bring back the cash to the USA. There will be no cash in the EU for them to collect.
Eventually they will settle for about $200 million.
Apple could "send" all its money back to the US but if they failed on all its appeals it would still have to pay the back tax.
EU won't waste their time. If there is no cash in the EU they have no leverage. Apple could play the waiting game for decades.
EU will settle with Apple for a much lower amount. Bottom line is EU has very little leverage against the USA, Apple, and Ireland.
Out of the four main figures (USA, EU, Apple, Ireland) the EU is the only one that is a parasite organization and may not even exist in 5 years.
Apple and Ireland can appeal. The appeal will probably take 2 years at least. If they lose they can appeal to a higher court. Another 2 years. Then finally to the European Court of Justice that would take 3 years.
I guess an import stop for iPhones would be pretty good leverage? I do like my iPhone but in the end any phone will do...
This will go to appeal and be stuck for at least 3 years. Then the US government will pass a law to bring back the cash to the USA. There will be no cash in the EU for them to collect.
Eventually they will settle for about $200 million.
Please do tell us what your sources are for this assessment...
All these Americans on this forum thinking, writing, screw EU, screw rules, appeals, just sit it out, the US govt will tackle this, ...
blah.blah.blah
remember the MDD-Boeing merger? Remember how vocal the US were against EU anti-trust scrutiny? Did it help? No!
The US have 0 authority in the EU. Planning on not doing business in the EU then (a retarted person's retaliation plan)? Then don't!
You fail to see the big picture here. The U.S. does have the upper hand. If an unfavorable ruling is handed down. Ireland will be appealing the decision. That could take at least 3 years. In the meantime, if the U.S. passes repatriation tax reform next year, then all of Apple's money will be out of reach of the EU.
So, if a company repatriates the money, they don't pay due taxes? Really?
Comments
It has been told to you many times.
This is not just about Apple: Google, Microsoft, Starbucks etc all use the same arrangement. What the EU is saying is that the arrangement itself is illegal, so Ireland will have to claw back the money from these outfits too.
The mistake that these companies made (and Microsoft keeps making) is that when it comes to these cases they can't really win because the EU is both the jury and the judge. Now since Ireland offered this deal to everyone then I'm a little unclear as to why these companies are getting an unfair advantage; it could be that offer wasn't open to everyone. No one seems to have the full details, but it looks like we'll find out tomorrow.
In any case calm down. This is not going to make any difference to Apple's books since the company has already (wisely as it turns out) accounted for the full amount of tax owed.
As for the EU itself; yes, it is coming apart at the seams (the UK stubbornly failed to implode after Brexit, so other countries will want to leave too), but that won't affect this judgement.
No, the deal was not offered to anyone, that is the case about.
And what Brexit? I didn't knew that UK had already triggered the Article 50 of the Lisbon Treaty and had leaved the EU
The EU wants to establish a system of fairness among its member nations but I believe this is going too far. The US could very easily decide to renegotiate its tax treaties and penalize the EU for this.
http://europa.eu/rapid/press-release_IP-15-5140_en.htm
blah.blah.blah
remember the MDD-Boeing merger?
Remember how vocal the US were against EU anti-trust scrutiny?
Did it help?
No!
The US have 0 authority in the EU.
Planning on not doing business in the EU then (a retarted person's retaliation plan)? Then don't!
It makes zero difference to me if Apple has 200 Billion in cash or 300 or more. Apple doesn't need to sell to every person on the globe or to every country in the world.
In any event, the EU is far from a bastion of free trade for anything outside of intra-EU trade.
If after all the appeals Apple will pay if they have to because they would have to be totally insane to give up the EU as a market.
The fact that you still have not got a simple, clear response tells you all you need to know. There are a lot of cheap name-callers among the pro-EU types here (and I've flagged one of them), but not a lot of honest responses to an obvious question.
The, fact that has been explained a lot of time tells all we need to know., There are a lot of people here that doesn't know anything and doesn't want to know/
Do you know an honest and clear answer?
http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52014XC1017(08)&from=EN
And then compare with what SOG35 says.